Toxic Release Inventory (TRI)

Toxic Release Inventory (TRI) is an Environmental Protection Agency (EPA) program established through Section 313 of the Emergency Planning and Community Right-to-know Act (EPCRA) of 1986. EPCRA was created to increase the health and safety of US citizens by monitoring hazardous substances and helping communities plan for chemical emergencies. TRI reporting allows the EPA to compile national release and transfer data for over 600 chemicals and chemical categories classified as a threat to human health. To comply with EPCRA Section 313, facilities meeting the applicability criteria below must determine if the manufacture and use thresholds were exceeded for any regulated toxic chemicals during the reporting year. If so, an EPA Form R must be submitted for each applicable chemical which includes information regarding releases, discharges, transfers, and more.

TRI Applicability Criteria

In order for TRI reporting obligations to apply, a facility must:

Be classified under a covered primary NAICS code. (A full list of covered NAICS codes can be found on the TRI website)

Reach or exceed 20,000 total annual facility work hours, taking into account all employees and contractors working for the facility

TRI Reporting Thresholds

Manufacturing

The manufacturing threshold for MOST toxic chemicals is 25,000 lbs/year and includes:

– Importing

– Intentional production

– Unintentional production

Processing

The processing threshold for MOST toxic chemicals is 25,000 lbs/year and includes:

– Use as a reactant

– Incorporation into a product

– Repackaging for distribution

– Sending off-site for recycle

OtherwiseUse

The otherwise use threshold for MOST toxic chemicals is 10,000 lbs/year and includes:

– Use as a chemical processing aid (e.g. solvent)

– Use as a manufacturing aid (e.g. refrigerant)

While this is a brief overview of the TRI applicability criteria and reporting thresholds, many other details about the program are not addressed here. For example, specific chemicals that are known to have severe health effects are not subject to the reporting thresholds shown above, but rather have reduced reporting thresholds.

Davenport Engineering, Inc. has extensive experience in TRI reporting, working for numerous businesses within different industries. We are able to provide all of your TRI needs. Contact us today to learn more about the TRI program, or to discuss how Davenport Engineering can assist with your TRI reporting.